EPA Proposed Changes to RMP

The EPA is currently making a move to overhaul the now 25-year old Risk Management Program (RMP) in response to a White House directive intending to provide more safety in chemical refineries. The RMP regulation governs how companies operate when using particularly hazardous compounds and chemical processes. The proposed changes stem from multiple large industrial accidents that occurred in 2013. After industrial accidents, the RMP currently requires an internal audit, which some groups claim is a conflict of interest. The proposed changes would now see a third-party audit as a requirement instead. The conditions that determine whether a company is bound by the regulation are also very ant

Hazard Communication Regulatory Update

As of June 1, 2016, there was a significant change to the OSHA Hazard Communication Standard (29CFR1910.1200). Employers are required to update labeling on hazardous chemical containers, improve their hazard communication programs, and administer employee training for any new physical or health hazards. Employers must ensure properly labeling on shipped containers include: • Signal word • Hazard statement • Pictogram • Precautionary statement As an alternative, employers may provide labeling of product identifier, pictures, symbols, or a combination of all three in conjunction with the hazard communication program to inform employees of the specific chemical hazards. In either case, the labe

NJDEP Issues reminder to Submit CRTK

NJDEP issued an advisory on July 5, 2016 regarding the Community Right to Know (CRTK) for 2015. This was due on March 1, 2016. However, the NJDEP believes that a significant number of regulated entities did not submit the annual CRTK because they either believed they were exempt from reporting requirements or they had difficulty setting up their online account to submit a CRTK. Therefore, the Department is clarifying that a regulated entity can only be exempt from CRTK reporting requirements AFTER submitting initial notification to NJDEP of such status. Entities that believe they are exempt may submit a CRTK reporting exemption form in lieu of having to set up an online account and submit a

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